GPSR Instructions for Use and Warnings Explained

You've imported a batch of wireless charging pads from China. Each one comes with a slip of paper in English and Chinese, with pictograms even you don't understand. You list the product on Allegro, and a week later a customer files a complaint: "there was no warning that you shouldn't charge through a metal case." Now you have a double problem — an unhappy customer and a gap in your GPSR compliance. Regulation (EU) 2023/988 treats instructions and warnings as part of product safety, not an add-on. This article shows exactly what they must include, and in what language.

Why instructions are a safety element

GPSR starts from the premise that a product is safe not only when it's well designed, but also when the user knows how to use it safely. That's why instructions and warnings are part of the safety assessment. If a product carries a risk that can't be fully eliminated through design, informing the user becomes mandatory. This is the last line in the risk-reduction hierarchy described in the article on product risk assessment.

Language: country of sale, not country of manufacture

This is the most important rule that trips up most importers. Instructions and warnings must be in a language easily understood by consumers in the member state where the product is made available. If you sell in Poland, they must be in Polish. If you also sell in Germany, you need a German version. An English-Chinese slip from your supplier doesn't meet the requirement, however accurate it might be.

It's not about word-for-word translation — it's about comprehensibility. Pictograms help, but they don't replace text where a warning needs to be unambiguous.

What the instructions for use must contain

The scope depends on the product, but good instructions usually cover:

• Intended use — what the product is for and who it's intended for.
• How to use it safely — how to switch on, operate, charge, assemble.
• Limitations — what not to do, under what conditions not to use it.
• Maintenance and storage — cleaning, replacing parts, storage conditions.
• What to do in case of a fault — what to do if the product doesn't work correctly.
• Identification and contact details — manufacturer, importer, Responsible Person in the EU.

Warnings — how to word them

A warning needs to be visible, legible and specific. A generic "use with care" means nothing. An effective warning states what the hazard is and how to avoid it. See the comparison below.

Weak warning	Good warning
Caution: danger	Choking hazard. Contains small parts. Not for children under 3.
Use as intended	Do not charge through a metal case — risk of overheating.
Do not get wet	Product is not waterproof. Do not use in the bathroom or outdoors in the rain.

Where to place warnings

Critical safety warnings should be placed where the user will see them before they start using the product — on the product itself, on the packaging, and in the instructions. A warning hidden on the last page of a leaflet in Chinese doesn't fulfil its purpose. For children's products, age warnings (e.g. "not for children under 3") are often explicitly required by standards.

Link to traceability and RP data

The instructions and label are the natural place for the data required by GPSR: the product's identification markings and the Responsible Person's details in the EU. A model or batch number lets you connect a warning to a specific series — more in the article on product traceability. The Responsible Person's details, in turn, must appear on the product or its packaging — we cover that in the article on RP details on the product and in the listing.

Instructions as part of the documentation

You attach the content of the instructions and warnings to the technical documentation. The market surveillance authority checks not only whether instructions exist, but whether they're in the right language and adequately address the identified risks. Instructions that align with the risk assessment are a sign of mature documentation.

Frequently asked questions

Is an English-only instruction manual enough?

No, not if you're selling to consumers in Poland. Instructions and warnings must be in a language the consumer understands in the country of sale — that means Polish. An English version can be an addition, but it doesn't replace the Polish one.

Do pictograms replace warning text?

Pictograms supplement, but don't always replace text. Where a warning needs to be unambiguous (e.g. an age restriction, risk of overheating), text in the language of the country of sale is needed.

Do the instructions have to be on paper?

Key safety warnings should be physically available with the product. The full instructions can often also be provided digitally, but not at the expense of the visibility of the most important warnings — especially for products used by children or older people.

Who is responsible for the Polish translation of the instructions?

The importer placing the product on the market. Even if the supplier provides the content, you're responsible for the instructions and warnings being correct and in the right language.